Privacy Policy
Effective Date: January 27, 2026
PRIVACY POLICY, AI TRANSPARENCY NOTICE & REGULATORY READINESS MEMORANDUM
NOTICE
This document sets out the privacy practices, artificial intelligence transparency disclosures, and regulatory compliance framework of ENABLED HR LABS INC. ("Sudburyjobs", "Company", "we", "us", or "our") in connection with its recruitment and employment technology platform operating as Sudburyjobs at sudburyjobs.ca, associated websites, applications, and services (collectively, the "Platform").
Sudburyjobs is powered by Enabled Talent, a workforce technology platform developed and operated by ENABLED HR LABS INC.
By accessing or using the Platform, all users acknowledge that they have read, understood, and agreed to the practices described herein.
SECTION 1: PRIVACY POLICY
1. Purpose and Scope
This Privacy Policy governs the collection, use, disclosure, retention, and safeguarding of personal information obtained through the operation of the Platform.
This Policy applies to all individuals and entities accessing or using the Platform, including job seekers, employers, institutional partners, representatives, and website visitors ("Users").
The Company is committed to protecting privacy, dignity, and autonomy in all information-handling practices.
2. Legal Compliance Framework
The Company's privacy practices are designed to comply with:
- applicable Canadian federal private-sector privacy legislation;
- Ontario provincial legislation governing employment standards, accessibility, and human rights; and
- applicable electronic communications and anti-spam legislation.
Where Users voluntarily provide disability-related, accommodation-related, or health-related information, the Company applies enhanced confidentiality and security safeguards consistent with recognized health-information protection standards.
3. Collection of Personal Information
The Company collects only personal information that is reasonably necessary to operate the Platform, deliver services, meet legal obligations, and improve system performance.
3.1 Information Provided by Users
The Company may collect:
- Identity and contact information, including name, email address, telephone number, mailing address, and optional profile image;
- Account information, including login credentials, preferences, and user role classification;
- Professional information, including resumes, education history, employment history, skills, certifications, and career preferences;
- Accessibility or accommodation information, where voluntarily disclosed;
- Employer information, including organization details, job postings, hiring preferences, interview records, and compensation information;
- Billing and transaction information processed through secure third-party payment service providers.
Disclosure of disability-related or accommodation information is strictly voluntary and may be withdrawn at any time.
3.2 Automatically Collected Information
When Users interact with the Platform, the Company automatically collects:
- IP address and approximate location;
- device type, browser type, and operating system;
- usage activity, interaction logs, and session data;
- cookies and similar tracking technologies.
This information is used for system security, fraud prevention, analytics, performance optimization, and accessibility improvements.
3.3 Information from Third Parties
The Company may receive limited personal information from:
- authentication or identity-verification services;
- analytics, communication, and cloud service providers;
- authorized employer or institutional partners.
4. Use of Personal Information
The Company uses personal information to:
- operate and maintain the Platform;
- create and manage user accounts;
- facilitate recruitment and job application processes;
- match job seekers with employment opportunities;
- deliver accessibility and accommodation features;
- personalize user experience;
- communicate service-related notices;
- prevent fraud, misuse, or security incidents;
- conduct analytics and improve system performance; and
- comply with legal and regulatory obligations.
The Company does not sell or rent personal information.
5. Sensitive Personal Information
Disability-related, health-related, and accommodation-related information is treated as sensitive personal information.
The Company:
- collects such information only where voluntarily provided;
- uses such information solely to support accessibility and accommodation services;
- restricts access to authorized personnel on a need-to-know basis; and
- applies enhanced technical and organizational safeguards.
Withdrawal of such information does not affect access to core Platform services.
6. Artificial Intelligence and Automated Processing
The Company employs artificial intelligence and statistical models to support:
- job matching and candidate recommendations;
- resume parsing and skill identification;
- accessibility optimization; and
- system performance enhancement.
Safeguards
- AI systems assist but do not make final hiring or rejection decisions;
- all recruitment decisions remain under human authority;
- AI outputs are subject to human review;
- sensitive disability or health information is not used for hiring decisions;
- Users may request information regarding AI-assisted processing affecting them.
7. Legal Basis for Processing
Personal information is processed on the basis of:
- User consent;
- performance of a contract;
- legitimate business interests; and
- compliance with legal or regulatory obligations.
Users may withdraw consent at any time, subject to legal or contractual restrictions.
8. Disclosure of Personal Information
The Company may disclose personal information:
- to employers where Users apply to positions or share profiles;
- to service providers supporting Platform operations;
- to affiliated corporate entities for internal operations;
- where required by law or court order; and
- in connection with corporate restructuring, merger, or sale of assets.
All third parties receiving personal information are required to maintain confidentiality and appropriate security safeguards.
9. Employer Obligations
Employers using the Platform act as independent controllers of personal information they receive and are solely responsible for compliance with employment, recruitment, and human rights laws. The Company does not control employer hiring decisions.
10. Cross-Border Data Transfers
Personal information may be processed or stored outside Canada. The Company implements contractual and technical safeguards to ensure appropriate protection for cross-border data transfers. Use of the Platform constitutes consent to such transfers.
11. Data Retention
Personal information is retained only for as long as necessary to provide services, meet legal obligations, resolve disputes, and enforce agreements. Thereafter, information is securely deleted or anonymized.
12. Security Measures
The Company implements reasonable administrative, technical, and physical safeguards to protect personal information, including encryption, access controls, secure infrastructure, and incident-response procedures. No system can be guaranteed completely secure, and Users accept this inherent risk.
13. User Rights
Subject to applicable law, Users may request:
- access to their personal information;
- correction of inaccurate information;
- withdrawal of consent;
- deletion where legally permissible; and
- information regarding AI-assisted processing.
Requests may be submitted to:
ENABLED HR LABS INC. (operating as Sudburyjobs)
Email: jeby@enabledtalent.com
14. Cookies and Tracking Technologies
The Platform uses cookies and similar technologies to maintain sessions and analyze usage. Users may control cookie settings through their browser. Disabling cookies may affect Platform functionality.
15. Minors
The Platform is not intended for individuals under sixteen (16) years of age without appropriate authorization. The Company does not knowingly collect personal information from minors under sixteen.
16. Amendments
The Company may amend this Policy from time to time. Continued use of the Platform constitutes acceptance of the amended Policy.
SECTION 2: AI TRANSPARENCY NOTICE
Sudburyjobs, powered by Enabled Talent, uses artificial intelligence to enhance recruitment efficiency, accessibility, and user experience.
AI is used to:
- recommend employment opportunities;
- identify relevant candidate skills;
- generate candidate summaries; and
- improve accessibility features.
AI is not used to:
- make final hiring or rejection decisions;
- evaluate disability or health information for employment decisions; or
- replace human judgment.
All employment decisions remain under human authority. Users may request information regarding AI-assisted recommendations affecting them.
SECTION 3: REGULATORY READINESS MEMORANDUM
Overview
The Company operates in a regulatory environment involving recruitment, data protection, accessibility, and artificial intelligence. The Company maintains governance practices designed to comply with current legal requirements and adapt to evolving legislative standards.
Compliance Commitments
The Company commits to:
- obtaining meaningful user consent for data collection and use;
- limiting data collection to defined purposes;
- implementing strong security safeguards;
- maintaining breach-response procedures;
- ensuring accessibility-first platform design;
- applying human oversight to AI systems; and
- requiring employer accountability in recruitment practices.
Conclusion
Sudburyjobs, powered by Enabled Talent, is committed to operating a lawful, privacy-respecting, and inclusive recruitment platform that protects personal information, ensures accessibility, and applies artificial intelligence responsibly.
ENABLED HR LABS INC. is the legal entity responsible for all data practices associated with the Sudburyjobs platform.